Case Summary (G.R. No. L-40294)

Automatic Review of Death Penalty Imposition

• The case involves an automatic review of a death penalty imposed by the Circuit Criminal Court of Pasig for the crime of murder.
• Six accused were initially charged, but one, Loreto Rivera, died during the proceedings.
• The incident occurred on November 18, 1971, when inmates from Brigade 3-C attacked inmates from Brigade 3-A, resulting in the death of Bernardo Cutamora.

Facts of the Case

• The attack was premeditated, stemming from prior mockery and humiliation faced by the accused from inmates of Brigade 3-A.
• The accused used a false key to exit their dormitory and attacked the victim while he was collecting food rations.
• All accused confessed to their involvement, citing a motive of revenge for previous insults.

Procedural History

• An Information for Murder was filed against the accused on April 24, 1973, after a delay due to the separation of a principal investigator.
• During arraignment, some accused pleaded guilty, while others entered not guilty pleas.
• The trial saw a withdrawal of guilty pleas and a repudiation of confessions by some accused, claiming duress.

Trial Court's Verdict

• The Trial Court found all accused guilty of murder and imposed the death penalty, along with financial indemnities to the victim's heirs.
• The court's decision was based on the evidence presented, including confessions and witness testimonies.

Grounds for Appeal

• The appellants raised several grounds for appeal, including the alleged coercion in obtaining confessions and the misapplication of aggravating circumstances.
• They contended that their confessions were extracted under duress and that the trial court erred in its findings.

Evaluation of Confessions

• The court found no evidence to support claims of coercion; the confessions contained specific details only the accused could know.
• The presumption of voluntariness of confessions was upheld, and the burden of proof to refute this presumption lay with the appellants.

Aggravating Circumstances

• The court affirmed the presence of treachery, evident premeditation, and recidivism as aggravating factors.
• The attack was sudden and unexpected, and the planning of the murder was evident from the timeline of events.

Imposition of the Death Penalty

• The trial court's imposition of the death penalty was deemed appropriate given the circumstances of the crime and the prior convictions of the accused.
• The law prescribes the maximum penalty for murder when committed by individuals already serving sentences for other crimes.

Final Judgment

• The judgment of conviction was aff...continue reading